SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST 

(In accordance with 40 CFR Part 51 - App. V) 

SIP Submitted by: The Delaware Department ofNatural Resources and Environmental Control (DE DNREC) 

Date Submitted: 12/12/2012 

Subject: Two redesignation requests and maintenance plans submitted via a single transmittal letter. 

(1) Delaware Redesignation Request and Maintenance Plan Under the 1997 Annual PM2.5 National Ambient Air Quality Standard; 

State Implementation Plan for the New Castle County Portion of the Philadelphia-Wilmington, PA-NJ-DE Nonattainment Area for 

Fine Particles 

(2) Delaware Redesignation Request and Maintenance Plan Under the 2006 Daily PM25 National Ambient Air Quality Standard; 

State Implementation Plan for the New Castle County Portion of the Philadelphia-Wilmington, PA-NJ-DE Nonattainment Area for 

Fine Particles 

Completeness Review 

Completed by: Maria A. Pino 

Date Completed: 30 January 2013 

Administrative Materials 

I EPA REQUIREMENT 

1

11. A formal letter of submittal from the Governor or his 

:~esignee, requesting EPA approval of the plan or revision 

hereof. 

!12. Evidence that the State has adopted the plan in the State code 

i r body of regulations; or issued the permit, order, or consent 

~greement in final form. That evidence shall include the date 

pf adoption or fmal issuance as well as the effective date of the 

iplan, if different from the adoption/issuance date. Check to see 

if the regulation, permit, order or consent decree has a sunset or 

~xpiration date. If so it is not acceptable as a SIP submission. 

3. Evidence that the State has the necessary legal authority 

:Under State law to adopt and implement the plan. 

I 

ACCEPTABLE 

STATE SUBMITTAL I(X) I 

1. Submittal letter dated December 12,2012 from DE DNREC X 

Secretary Collin P. O'Mara to Shawn M. Garvin, Regional 

Administrator EPA Region III 

2. Secretary's Order No. 2012-A-0042, Re. Revisions to X 

Delaware State Implementation Plan for Redesignation 

Requests and Maintenance Plans Under the 1997 Annual and 

2006 daily Fine Particulate Matter National Ambient Air 

Quality Standards. 

Date oflssuance: 11/27/2012 

Effective Date: 11127/2012 

3. Section 6.2 of both redesignation requests and maintenance X 

plans states, "Delaware has the legal authority to implement 

and enforce specified measures necessary to attain and maintain 

the NAAQS." Delaware has legal authority to adopt, 

implement, and enforce rules, regulations, and plans under Title 

7, Delaware Code, Chapter 60. 
EPA REQUIREMENT STATE SUBMITTAL (X) 

114· A copy of actual regulation, or document submitted for 4. (a) "Delaware Redesignation Request and Maintenance Plan X 

fapproval and incorporation by reference into the plan, including Under the 1997 Annual PM2.s National Ambient Air Quality 

indication of the changes made to the existing approved plan, Standard, State Implementation Plan for the Philadelphiawhere applicable. The submittal shall be a copy of the official Wilmington, PA-NJ-DE Nonattainment Area for Fine 

State regulation/document signed, stamped, dated by the Particles," Final, November 27, 2012; and 

appropriate State official indicating that it is fully enforceable (b) "Delaware Redesignation Request and Maintenance Plan 

by the State. The effective date of the regulation/document Under the 2006 Daily PM2.5 National Ambient Air Quality 

shall, whenever possible, be indicated in the document itself. Standard, State Implementation Plan for the PhiladelphiaWilmington, PA-NJ-DE Nonattainment Area for Fine 

Particles," Final, November 27, 2012; 

5. Evidence that the State followed all of the procedural 

5. Secretary's Order 2012-A-0042, dated November 27, 2012. X 

Cover letter transmitting the SIP revision dated December 12, equirements of the State's laws and constitution in conducting 2012. Copy of public hearing notices. Certification of public ~d completing the adoption/issuance of the plan. hearing notice. 

6. Evidence that public notice was given of the proposed 6. The submittal included a copy of the notice of public hearing X 

change consistent with procedures approved by EPA, including and public comment period that was published in the News 

he date of publication of such notice. Journal, the Delaware State News, the News from Delaware's · 

Office of Environmental Protection, and on the Delaware State 

Calendar at http://egov.delaware.gov/pmc/event/details/18856. 

7. <:;ertification that public hearings were held in accordance 7. The December 6, 2012 Hearing Certification shows that the X 

twith the information provided in the public notice and the hearing was held on October 23, 2012, in accordance with the 

State's laws and constitution, if applicable. public notice. The December 12, 2012 submittal letter certifies 

that a public hearing was held through the process established 

by the State of Delaware with proper 30 day notice prior to the 

hearing. 

8. Compilation of public comments and the State's response 8. Hearing Officer's Report dated November 19, 2012. X 

hereto. 

Technical Materials 

11. Identification of all regulated pollutants affected by the plan. 1. In both maintenance plans, Chapter 8, Maintenance X 

Demonstration, indicates that PM2.s, NOx, and S02 are the 

regulated pollutants. 

2. Identification of the locations of affected sources including 2. In both redesignation requests and maintenance plans, the X 

the EPA attainment/nonattainment designation of the locations Delaware portion ofthe Philadelphia-Wilmington, PA-NJ-DE 

and the status of the attainment plan for the affected area(s). PM2.5 nonattainment area, i.e., New Castle County, is identified. 
EPA REQUIREMENT STATE SUBMITTAL (X) 

~. Quantification of the changes in plan allowable emissions 3. In both maintenance plans, Chapter 8, Maintenance X 

from the affected sources; estimates of changes in current Demonstration, contains quantifications ofPM2.s, NOx, and 

actual emissions from affected sources or, where appropriate, S02 levels (emissions inventories/budgets). For the 1997 

quantification of changes in actual emissions from affected annual PM2_5 NAAQS plan, 2017 and 2025 projected 

sources through calculations of the differences between certain inventories are compared to the 2007 emissions inventory. For 

baseline levels and allowable emissions anticipated as a result the 2006 24-hour PMz.s NAAQS plan, 2017 and 2025 projected 

of the revision. inventories are compared to the 2008 emissions inventory 

4. The State's demonstration that the national ambient air 4. Both maintenance plans demonstrate that PMz.s, NOx, and X 

jquality standards, prevention of significant deterioration S02 emissions levels in 2017 and 2025 will be below the level 

increments, reasonable further progress demonstration, and required to maintain the PMz.s standards (2007 attainment year 

!Visibility, as applicable, are protected if the plan is approved for the 1997 annual PM2_5 NAAQS, 2008 for the 2006 24-hour 

fand implemented. PMz.s NAAQS). 

5. Modeling information required to support the proposed 5. Emissions modeling technical information is provided in the X 

ifevision, including input data, output data, models used, "2008 Attainment Year State Implementation Plan Emissions 

!ambient monitoring data used, meteorological data used, Inventory for PM2.5, S02 and NOx New Castle County, 

·ustification for use of offsite data (where used), modes of Delaware I FINAL REPORT/ Submitted to: U.S. 

models used, assumptions, and other information relevant to the Environmental Protection Agency Region 3 - Philadelphia, P A 

determination of adequacy of the modeling analysis. I Prepared by: Department ofNatural Resources & 

Environmental Control Division of Air Quality Emission 

Inventory Development Program, and in 3 documents prepared 

for the Mid-Atlantic Regional Air Management Association 

(MARAMA), all dated January 23,2012. 

(1) Technical Support Document for the Development of the 

2007 Emission Inventory for Regional Air Quality Modeling in 

the Northeast I Mid-Atlantic Region Version 3.3; 

(2) Technical Support Document for the Development of the 

201 7 I 2020 Emission Inventories for Regional Air Quality 

Modeling in the Northeast I Mid-Atlantic Region Version 3.3; 

(3) Technical Support Document for the Development of the 

2025 Emission Inventory for PM Nonattainment Counties in 

the MANE-VU Region Version 3.3 Rev.2. 

6. Evidence, where necessary, that emission limitations are 6. Not applicable. X 

based on continuous emission reduction technology. 
EPA REQUIREMENT STATE SUBMITTAL (X) 

7. Evidence that the plan contains emission limitations, work 7. In both maintenance plans, Chapter 8, Maintenance X 

practice standards and recordkeeping/reporting requirements, Demonstration, contains 2017 and 2025 emissions inventories I 

where necessary, to ensure emission levels. budgets for PM2.5, NOx, and SOz levels as well as an 

accounting of emissions control measures to ensure emissions 

levels. 

8. Compliance/enforcement strategies, including how 8. In both maintenance plans, Chapter 9, Verified Continued X 

compliance will be determined in practice. Attainment, contains strategies to monitor emissions levels to 

ensure that they remain below attainment levels. In both plans, 

Section 3.4 contains a commitment that, once redesignated, the 

state will continue to operate an appropriate monitoring 

network to verify the maintenance of the attainment status. In 

both plans, Chapter 10, Contingency Measures, identifies 

contingency measures that will be implemented if the area 

violates or exceeds the PM2.5 standard, or if emissions levels 

increase more than 10% above the levels in theattainment year 

emissions inventory. These measures are intended to maintain 

the NAAQS, or bring the area back into attainment. 

9. Special economic and technological justifications required by 9. Not applicable. X 

any applicable EPA policies. (If a policy is not appropriate, 

explain why.) 

10. A Section 107 request must be accompanied by a 10. The submittal includes maintenance plans for both the 1997 X 

maintenance plan demonstrating maintenance to the relevant and 2006 PM2.5 NAAQS that provide for maintenance through 

NAAQS for at least 10 years after redesignation. 2025, which is a least 10 years after redesignation . 

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